Keeping up with the strict dos and don’ts of Defined Benefit (DB) Transfers can be challenging. The FCA are very prescriptive about what good and bad practice looks like in DB transfer advice, having released their Finalised Guidance FG21/3: Advising on pension transfers in March 2021. In section 1.4 of the guidance, they summarise the issues:
In our ongoing work, we have seen some high quality DB transfer advice that has enabled consumers to make the best use of their funds. But much of the advice we have reviewed shows that too many firms are struggling to give consistent, suitable advice which meets our rules to consumers. This is largely due to poor practices or weak record keeping. As a result, too much of the DB transfer advice we have seen is either unsuitable or we were unable to assess its suitability due to material information gaps (MIGs). MIGs occur where firms have not collected the necessary information, usually about the consumer or the scheme benefits, to assess suitability. Even where the advice is suitable, we have seen too many poor practices in the advice process based on a misunderstanding of the requirements, poorly designed systems, outdated processes or inadequate disclosures."
"We are publishing this guidance to help firms give suitable advice consistently"
FCA Finalised Guidance FG21/3 1.2
Probably one of the biggest developments to stem from the FCA’s focus on DB transfers was the need for triage. You’ll know by now what needs to be included in a triage process (but in case you want a reminder, see here), and be aware of requirements like giving full information on DC pensions as well as DB pensions, while not straying into the realms of formal advice in the process.
Meeting all of these additional requirements can be a challenge in itself. Evidencing that you have met them to the FCA and PI insurers can be a tougher challenge still.
The key to a successful triage process is consistency and impartiality. Offering the same, compliant information at the same point in your process, for each and every client means that you can be confident that nothing has slipped through the cracks. However, this still sounds like a lot of work and effort. This is where technology can do a lot of the heavy lifting for you. By using Money Alive’s video engagement platform, you can deliver the same information to each and every client when they first approach you about their DB pension.
Damian McPhun - Partner (specialising in professional liability claims) - Beale & Co Solicitors LLP :
"We are seeing a number of firms using the Money Alive videos and, of course, the fact that the underlying client journey is recorded and evidenced means that there are no issues about whether or not the client understood the nature of the pension transfer and the relevant issues. More importantly, we are seeing clear benefits for firms utilising the videos in that:
- We have seen positive feedback from FCA reviewers about the fact that firms have provided the Money Alive DB pension transfer videos to clients – in terms of showing client engagement and the firm having a positive approach to educating the client; and
- The use of the Money Alive DB pension transfer videos is being seen by PI Insurers as evidence that the firm is seeking to ensure clients have a good understanding of the subject matter – meaning it is more likely that the overall advice process will be compliant and less likely to result in a future complaint.
So we are seeing the videos have a very positive impact!"
As your client views the video box set that you’ve sent them, you’ll be able to track their progress, see any questions that they have along the way and get their confirmation of understanding, all through an easy to understand dashboard. You can also generate client reports, capturing all this invaluable information to save on file.
Better still, all of the content within the platform is managed by Money Alive. This means you can rest easy, knowing that it’s always kept up to date and in line with current regulation. Furthermore, the Money Alive box set is accredited by the Pension Management Institute giving extra confidence to you and your clients.
How it works
1. Onboarding - Sign into the Money Alive admin and invite your first client. All you need is their name and email address. The platform will generate an invite email and give you the chance to review/edit before sending.
2. Client experience - Once your client receives the invite he/she simply needs to sign in with their email address and access code (provided). No client registration is required and they start/stop the video experience as many times as required.
3. Reporting - From the moment you invite your client through to when they complete the journey, the platform documents their progress on the client's engagement report which you can download as a PDF and save on the clients file. This includes their invite email, video completed, question asked. To complete each video the client is asked if they understood the chapter so you can evidence their understanding.
Who’s it for?
Anyone involved in the Defined Benefit Pension Transfers process. This can include advisers that don’t advise on DB Transfers but who like to triage clients before referring on to an Adviser that does. The FCA doesn’t view the triage element as advice.
Why use Money Alive?
Money Alive is a market leader in video engagement and our multi-award winning platform is trusted by hundreds of firms to deliver educational content through our unique interactive video experiences.
Find out more
Schedule a 30 minute demo to see more of the platform, our video library and discuss how we could go about supporting your business objectives.